Privacy Policy

Version 1.0 | Effective date: May 28, 2025

At Aether Capital LLC (“Aether Capital,” “we,” “us,” or “our”), your privacy matters. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you access our website, investor portal, or other online investment-related services (collectively, the “Services”).

These Services are intended solely for individuals or entities with a pre-existing relationship with Aether Capital LLC and do not constitute public solicitation. By using the Services, you consent to the collection and use of your information as described in this Policy.

1. Information We Collect

1.1 Information You Provide

We collect personal information you voluntarily provide when you:

  • Establish a relationship with us

  • Inquire about or subscribe to investment opportunities

  • Complete investor documentation

  • Contact us for support

This may include:

  • Name, email address, and phone number

  • Investment details, account credentials, and contact preferences

  • Documentation submitted during fund subscription processes

1.2 Information Collected Automatically

We may collect limited technical data during your use of the Services, including:

  • IP address, browser type, operating system, and access timestamps

  • Device identifiers and cookie data

1.3 Information from Relationships

In accordance with Rule 506(b) of Regulation D, we may collect information through pre-existing business relationships or personal introductions to satisfy private placement regulatory requirements.

2. Use of Information

We use your personal information to:

  • Establish and manage investor relationships

  • Provide secure access to the Services

  • Fulfill legal and regulatory obligations

  • Send fund updates, administrative notices, or investor communications

  • Improve the performance and security of the Services

We process this information based on contractual necessity, legal compliance, and our legitimate business interests.

3. Sharing of Information

We may share your information:

  • With legal and regulatory service providers

  • With authorized third-party vendors supporting the platform (e.g., hosting or reporting tools)

  • When required by law or regulatory authorities (e.g., SEC, IRS)

  • In the event of a merger, acquisition, or other corporate transaction

We do not sell or publicly disclose your personal information for marketing purposes.

4. Data Security

We use industry-standard technical, administrative, and physical safeguards to protect your information. However, no system is completely secure. You are responsible for maintaining the security of your access credentials.

5. Data Retention

We retain personal information as long as necessary to:

  • Meet legal and regulatory requirements

  • Support investor relationship management and financial reporting

  • Maintain internal business records

6. Your Rights & Choices

You may:

  • Request access to, update, or correct your personal information

  • Request deletion of your data, subject to applicable retention laws

  • Opt out of non-essential communications by using “unsubscribe” links or contacting us directly

7. Cookies and Analytics

We may use cookies and analytics tools to improve site functionality and user experience. You can manage cookies through your browser settings. No identifiable investment data is tracked using cookies.

8. Aggregate and De-Identified Data

We may use anonymized or aggregated data for internal research, product development, or regulatory reporting. This data is stripped of personal identifiers and cannot be linked back to you.

9. Children’s Privacy

The Services are intended for users aged 18 or older. We do not knowingly collect personal data from individuals under 18. If we become aware of such collection, we will delete it promptly.

10. International Data Transfers

If you are located outside the United States, your data may be transferred to, processed, and stored in the United States. U.S. data protection laws may differ from those in your country.

11. Governing Law

This Privacy Policy is governed by the laws of the State of Delaware, without regard to conflict of law principles.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Revisions will be posted on this page with a new effective date. Your continued use of the Services constitutes acceptance of the revised terms.

13. Contact Us

For questions or concerns about this Privacy Policy, contact us at: support@aethercapital.xyz